Identifying and Evaluating Impacts - Mining and the Environment: From Ore to Metal - page 442

advocacy groups, some bias is to be expected. Even if the stakeholders were entirely objec-
tive, i nancial, technical, or scientii c constraints would introduce subjective view-points.

Study Team and Potential Confl icts of Interest

In preparing an EIA, mining companies may sometimes rely on in-house resources, or
more commonly arrange for work to be performed by external resources, usually environ-
mental consulting i rms and/or research institutions. If the EIA is prepared in-house it is
indeed difi cult to convince the public of the objectivity of related efforts. Moreover, many
jurisdictions prohibit this approach. Consequently, most mining companies routinely rely
on the services of consulting i rms, recognizing that outsourcing is usually more efi cient
and provides access to more specialized expertise than available in-house. Outsourcing
does not entirely resolve the problem of objectivity. External stakeholders may be con-
cerned about the possibility of bias by consulting i rms, selected and paid directly by the
mining company. In addition mining companies often provide guidance to consultants
throughout the preparation of the EIA to ensure that the EIA correctly rel ects practical
mining experience available in-house. Such guidance, while it may be seen as introduc-
ing the proponent's bias, is of course benei cial and in fact essential, considering that the
mining operator not the consulting team owns the EIA and will have to live with all the
management and monitoring commitments it contains. Experience demonstrates that
environmental management and monitoring measures designed by consultants with an
academic or research background are often impractical to implement. Critical review by
project engineers can assist in making these measures more practicable and effective.
A point often made is that consultants are obliged or i nancially bound to submit an
environmental assessment in favour of the project, and the objectivity of the assessment
is therefore questionable. Consultants, it is argued, are hardly likely to bite the hand that
feeds them. It is also argued that the mining company could attempt to exert inl uence
over consultants in many other ways. For example, the company could select a consult-
ant known to have a perspective likely to produce a positive assessment of the project; or
attempt to inl uence the consultant's work by the lure of future work (or the exclusion
in future work). While understandable, these perceptions seldom hold true in practice.
Admittedly potential conl icts of interest do exist but are rare. Today, the environmental
assessment process is too transparent to allow inappropriate collusion between the project
proponent and the EIA compiler. It should be also recognized that similar conl icts of inter-
est are unavoidable, no matter which party is responsible for preparing the environmental
assessment. More and more, the interests of mine proponents, environmental consultants
and other participants in the EIA process are converging. All parties seek (or should seek)
a positive outcome in which serious environmental problems are avoided or mitigated,
and in which sustainable benei ts will accrue to local communities. Should the results be
otherwise, this rel ects badly, not only on the proponent, but on the consulting i rm and its
individual team members, and on the regulatory authorities, whose responsibility is
(usually) not to prevent development but to ensure that it occurs without unacceptable
impacts.
To address concerns of real or perceived bias and quality lapses, mining companies can
consider implementing a range of measures: pre-qualifying consultants based on strict
requirements; selecting consultants in consultation with qualii ed independent third party
advice; hiring a separate consulting i rm or individual experts to conduct a peer review of
documents; and facilitating an expanded (earlier and more accommodating) public partici-
pation process.

Outsourcing does not entirely
resolve the problem of
objectivity.

Consultants, it is argued, are
hardly likely to bite the hand that
feeds them.